Privacy

Please be aware that you have the following data protection rights:

• The right to be informed about the personal data the Company processes on you;
• The right of access to the personal data the Company processes on you;
• The right to rectification of your personal data;
• The right to erasure of your personal data in certain circumstances;
• The right to restrict processing of your personal data;
• The right to data portability in certain circumstances;
• The right to object to the processing of your personal data that was based on a public or legitimate interest;
• The right not to be subjected to automated decision making and profiling; and
• The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting James Hunter.

The Company will retain your personal data only for as long as is necessary. Different laws require us to keep different data for different periods of time.

The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.

We must also keep your payroll records, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by HMRC and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

In this policy the following terms have the following meanings:

‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;

‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;

‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller;

‘personal data’* means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;

‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;

‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions. [Note 1]

* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.

‘Supervisory authority’ means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).

All of these definitions are italicised throughout this policy to remind the reader that they are defined terms

Your information will come to us in a variety of ways.

1. You may send your personal details to us directly via:

   • an application or registration form
   • email
   • post
   • via our website

2. We may be sent your data by the agency performing work seeking services for you. This information will only be accessible by us when they commence work finding services for you and require TrustHub to complete your Safeguarding and ensure you are suitable to work in the roles they are seeking to introduce you to.

   We receive this data electronically using a secure connection to their database.

3. We may receive your data from other third parties who you have agreed can provide you with work-seeking services such as any hiring company that uses our services to carry out or verify their employment screening.

This is an integral part of providing the benefits of our services to you and leads to much of the time saving efficiencies gained from TrustHub’s service.

Overseas Transfers

The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of facilitating your work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

In order to process your data we are required by the GDPR to have a legal basis for doing so.

There are a number of different legal bases for processing data and these will change as you progress through different stages of our service.

The legal bases we rely upon to offer these services to you are as follows:

• Legitimate interest

  • The Company will collect your personal data in order to provide employment screening and checking services
  • Processing your data will facilitate work finding services to both candidates and clients as part of our business.
  • We process personal data in order to be able to provide these services, including the checking of identity, right to work and qualifications as pay and to manage entitlement to certain statutory rights.

  It is in the legitimate interests of all parties involved, the recruitment companies, work-seekers and other clients, that The TrustHub Group Ltd can process personal data.

• Legal obligation

  • In certain industries it is a legal requirement for certain checks to be undertaken to ensure the suitability of applicants for the work they are applying for. This includes sensitive information such as Disclosure and Barring Service (DBS) Certificate criminal record checks.

• Contractual obligation

  • If you are successful in your application for an assignment or permanent job, we may process your personal data and sensitive information required for payroll and employment purposes. This will be to satisfy a contractual obligation we have with our clients and will facilitate you to satisfy any contractual obligations you may have directly with them.

  • When your personal data is required by law or to satisfy a contractual requirement (e.g. our client may require this personal data), or it is a requirement necessary for us or for you to enter into a contract with them.

    In these circumstances, you are obliged to provide the personal data and if you do not the consequences may be that:

    • You may not be permitted to continue with your application for work
    • You may not be permitted to commence an agreed work placement
    • You may not be permitted to continue on any work placements that have already commenced

We send your data to a number of different places in order to provide you with our service. Your data will be shared with:

• the Recruitment Businesses who refer you to us
• their Clients who show an interest in engaging you through the agency
• any of our affiliated Recruitment Businesses if you register with them after you have registered with us
• their Clients who show an interest in hiring you.

You can see an infographic of what happens with your data here